William H. Steere
P.O. Box 4808
Syracuse, N.Y. 13221
RE: The tariff classification of fuel cell component parts
(inverter and gas generator) from Japan.
Dear Mr. Steere:
In your letter dated June 12, 1990, you requested a tariff
The articles which are parts of the PC25 fuel cell are
described as follows:
1. The Electrical System Assembly module which contains all of the
electrical equipment plus, some equipment associated with the DC
System; specifically a. some items of the Cabinet Ventilation System
(CVS) which provides purge and ventilation air to power plant
equipment, b. some items of the air processing system which supplies
process air to the DC System, and c. some elements of the Water
treatment System (Resin Bottles). The principal function of this
module appears to be the conversion of direct current (DC) to
alternating current (AC).
2. The reformer is the unit that converts natural gas and steam into a
gas that is mostly Hydrogen. The gas is then fed to the fuel cell
which generates the DC for inversion to AC.
The applicable subheading for the DC module will be 8504.40.0040,
Harmonized Tariff Schedule of the United States (HTS), which provides
for "Static converters." The rate of duty will be 3 percent ad
The applicable HTS subheading for the reformer will be
8405.10.0000, which provides for "Producer gas or water gas
generators." The rate of duty will be 2.8 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport